WASHINGTON — The Space Development Agency was officially established as of March 12 — a move that goes against the wishes of the U.S. Air Force’s top civilian, who slammed the Pentagon’s plan for adding bureaucracy, creating risk by removing jobs and starting a new project that has yet to be validated, according to a memo obtained by Defense News.

Air Force Secretary Heather Wilson’s memo, dated Feb. 28, offers a scathing rebuke of the Space Development Agency, a pet project for both acting Defense Secretary Patrick Shanahan and Under Secretary of Defense for Research and Engineering Michael Griffin.

The top Air Force official argues that the Office of the Secretary of Defense, or OSD, has not adequately laid out how to transfer the authority of the SDA to the Space Force, which was provisioned in a Jan. 19 memo by the defense secretary titled “Guidance for the Establishment of the Space Development Agency.”

The SDA also “appears to replicate existing ones already ordered by Congress,” she wrote. She points to a memo by the OSD, which states that the SDA would be modeled on organizations like the Air Force Rapid Capabilities Office, even as the service Air Force has launched a space-focused version of the agency called the Space Rapid Capabilities Office.

“Until the Space Development Agency has a uniquely identifiable mission that cannot be accomplished by current organizations, the plan should not move forward,” she wrote.

Over the past month, Wilson has emerged as a strong critic of the SDA, telling reporters in February that she still had questions about the mission of the organization and over what it could do differently or better than existing entities.

She has since announced her resignation and is set to leave her office in May. However, her dissent is notable, because the next Air Force secretary will be tasked with leading the U.S. Space Force ― if its creation is approved by Congress. The new military branch is slated to at some point be tasked with overseeing the SDA, which is currently under Griffin’s purview.

Wilson’s memo responds to a second memo out of the OSD, titled “Qualification of Savings to Establish Space Development Agency,” which lays out an argument that as many as 55 civilians and 75 military jobs could be cut across the current space portfolio, which would offset the projected government staff requirement for the SDA.

Those cuts would come from the Missile Defense Agency (20 civilians and 15 military personnel), the U.S. Air Force Remote Sensing Directorate (15 civilian and 30 military), and a trio of service divisions focused on protected satellite communication, wideband SATCOM and advanced development (20 civilian and 30 military).

A fully staffed SDA will feature approximately 225 personnel, made up of 67 civilian, 45 military and 113 support contractors, per the memo. That would leave a net cut of 18 jobs across the department, which the qualification memo states will definitively save the Pentagon money.

In essence, the SDA would be a leaner, less bureaucratic alternative to existing space procurement organizations by stripping personnel from a number of agencies and eliminating a handful of Defense Department positions altogether, the qualification memo argues.

But that’s too risky a gamble to make without further analysis, Wilson argues in a different memo to Griffin dated Feb. 26.

“The ‘Quantification of Savings’ paper suggest that harvesting personnel from existing office that perform critical missions today ‘could’ result in savings, without addressing the risk to such programs if personnel were removed,” Wilson wrote. “The plan should not move forward until the proper analysis has been completed and coordinated. Absent rigorous supporting analysis, validation and verification of such savings, we do not recommend Secretary of Defense certification.”

In addition to criticizing the structure of the SDA, Wilson also lambasted its first major procurement effort.

The first big project the SDA will work on is what the memo calls the “transport layer” in low-Earth orbit — a large number of mass-produced small satellites networked together to provide “global, persistent, low-latency data transfer between and among the space and ground elements and the strategic and tactical military users of the next-generation architecture.”

In the long term, the SDA will be charged with procuring “not just the data transport layer but additional capabilities such as an alternate positioning, navigation and timing system, low-latency targeting, and improved detection, tracking and defense of ballistic and advanced missile threats.”

However, Wilson argues that the Air Force and the director of the Cost Analysis and Program Evaluation office are still conducting detailed work on whether that disaggregated satellite architecture will be better than current plans.

“It is premature to conclude that a massively proliferated low-Earth obit architrave would be more resilient in the face of deliberate attack than alternative, similar price architectures,” she writes. “The proposed plan requires in-depth supporting analysis and validation by the warfighting.”

Long-standing differences

Speaking last month at the Air Force Association’s winter meeting in Orlando, Wilson was upfront about her skepticism of the SDA.

“I have some concerns about what is the mission of this entity, why do we think it would be better than what we currently do, and what exactly will it be focused on conceptually,” she said. “I expect there would be public discussions on this. Conceptually, it would be stood up and then rolled into a Space Force, which means that it would be in a new agency that would exist for probably less than a year. So I think there [are] still questions."

When the Pentagon released its legislative proposal for the Space Force, there was noticeably little included about the SDA. A senior Pentagon official, however, said that was by design to focus the attention on the Space Force creation, adding that a new memo on the SDA is coming, perhaps as soon as this week.

Asked about the disagreement between Wilson and Griffin on the role of the SDA, the official was blunt: “Dr. Griffin will win in the end on this one.” The official added that was true even before Wilson made her announcement that she would be departing the Pentagon in May.

The calculus has dramatically changed since then.

The fight over the SDA is, in many ways, a fight over who controls the future of the space portfolio. Getting the Space Force to live within the Air Force, even if just temporarily for a few years, was a major win for Wilson and her team. But the SDA exists outside the Air Force, and will only move within the Space Force when, or if, that new branch stands up independently.

Notably, the fiscal 2020 budget request included $306 million to stand up the headquarters of the Space Force, establish U.S. Space Command and create the Space Development Agency — and of those three, the SDA got the most money, with $149.8 million in new funding that cannot be transferred from other parts of the budget.

It’s unclear what this money will go toward. The budget provides a general description of the role of the SDA, saying it will “will have a development mindset and will be focused on experimentation, prototyping and accelerated fielding, as well as leveraging commercial technologies and services.” However, it does not lay out why the SDA’s stand-up costs are equal to that of U.S. Space Command and the Space Force combined, especially as the SDA — with 20 transfers and 30 new employees — is smaller than the other two offices.

Asked about that dollar figure, Griffin declined to comment, but said details will be available when the Pentagon’s j-books are released in the near-future.

In the past, Shanahan and Griffin have talked about the SDA as the core of what the Pentagon will do in the space domain. In October, Shanahan described it as “where all the players go” if they want to do something with space assets, later telling Defense News that he needs someone in that job focused on how to architect common standards across the department.

“This is that integrated environment that we have to protect, and the best way to be able to provision for the future is to develop a foundation that’s rooted in a very well-defined architecture and standards,” Shanahan, then the deputy secretary, said. “And the standards aren’t just simply for interfaces, these are design standards, you’re manufacturing standards, these are test standards — so it’s a suite of those things.”

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